Armstrong 1: Correspondence

5055 TOPANGA CANYON BOULEVARD

CONTOS 8c BUNCH

LAWYERS

SUITE 400

.

WOODLAND HILLS. CALIFORNIA 91367
(213) 716-9400

MANUFACTURERS BANK BUILDING
1201 DOVE STREET

August 29 , 19 8 3 penthouse

NEWPORT BEACH. CALIFORNIA 92660
(714) 752-0400

REPLY TO: Woodland Hills

John G. Peterson, Esq.

TRABISH & PETERSON *

4676 Admiralty Way, Ste. 902

Marina del Rey CA 90291 •

#

Re: Church of Scientology of California vs.

Gerald Armstrong; Case No. C420 153

Dear Mr. Peterson:

On August 19, 1983, I met with you and Michael Magnuson
regarding your client's response to our First Request for
Production of Documents.

With respect to Request Nos. 1, 2, 14, 15 and 16, you decided
to stand on your client's objections and would not agree to
produce the documents requested therein.

With respect to Request Nos. 3-4, you agreed to provide any
written communication between your client and Omar Garrison
and others regarding the biography project.

With respect to Request No. 5(a), you stated a search would be
made for the original Petition of Mr. Armstrong to L. Ron Hubbard,
and produce it if it could be found. If it could not be found,
you agreed to make a written reponse indicating what steps were

taken to locate the original Petition.

. »

With respect to Request No. 5(b), you agreed to follow the same
procedure as outlined for Request No. 5(a) in attempting to
locate the letter from Pat Brice.

With respect to Request No. 6, you agreed to provide the original

agreement of October 30, 1980, if it was possible to obtain.

With-respect to Request No. 7, you agreed to search for all -
communications during 1982 from the DK Publications Organization,
and would make available any documentation that was not privileged.

With respect to Request No. 9, you agreed to provide a "pre¬
printer work copy" of the suppressive person declare on Mr.

Armstrong.

'—' V-

John G. Peterson, Esq.

TRABISH & PETERSON

Church of Scientology vs. Armstrong
Page Two

With respect to Request No. 10, you stated you would check to see
what Flag Conditions Order No. 6439 was and would get back to me.

With-respect to Request No. 11, you agreed to search for a time
track and proposal prepared by Vaughn Young dealing with the
biography, and would review them for relevancy. Once you had
reviewed them, you agreed to get back to me with a response.

With respect to Request No. 12, you indicated a likelihood that
Mr. Armstrong's personnel, ethics and B-l files would be produced
pending authorization of your client. You also requested that
should your client agree to production, Mr. Armstrong would be
required to provide a release. You would not agree to turn over
pre-clear and auditing files of Mr. Armstrong.

Following our discussion, it was agreed that you would provide me
with a written response or with production of documents by August 26
1983. That date has come and gone and I have heard nothing from you

I request that you advise me as to the status of the production of
these documents because it has been quite some time since we first
requested their production.

In addition, I again request that you send me the declaration you
filed in connection with the Order to Show Cause re Contempt on
Michael Flynn.

> Thank you for your anticipated courtesy and cooperation. v

Very truly yours,

CONTOS & BUNCH

JULIA DRAGOJEVIC

JD: pr

cc: Howard Stechel, Esq.

Michael Magnuson, Esq.
Gerry Armstrong